DCIT, PUNE vs. BAJAJ ALLIANZ LIFE INSURANCE COMPANY LIMITED, PUNE

ITA 653/PUN/2024Status: DisposedITAT Pune29 October 2024AY 2016-17Bench: SHRI R. K. PANDA (Vice President), MS ASTHA CHANDRA (Judicial Member)16 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that income from the shareholders' account in a life insurance company is part of the life insurance business and should be taxed accordingly, following High Court precedents. It also upheld the CIT(A)'s decision on the issue of excess provision for tax.

What were the facts?

The Revenue appealed against the CIT(A)'s orders concerning disallowance of expenses under Section 14A and the treatment of excess provision for tax in life insurance business. The Assessing Officer had made additions for both these issues.

What were the issues?

Whether expenses relatable to exempt income should be disallowed under Section 14A, and whether surplus in the shareholders' account of a life insurer is taxable as part of the life insurance business.

Which sections of the Income-tax Act were involved?

Section 14A,Section 44

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & MS ASTHA CHANDRA

For Appellant: Shri Percy Pardiwalla &, Ms. Vasanti B Patel (through virtual)
For Respondent: Shri P R Mane

PER R.K. PANDA, VP :

The above two appeals filed by the Revenue are directed against the separate orders dated 09.02.2024 and 12.02.2024 of the CIT(A) / NFAC, Delhi relating to assessment years 2016-17 and 2018-19, respectively. Since identical grounds have been raised by the Revenue in both these appeals, therefore, for the sake of convenience, these were heard together and are being disposed of by this common order.

2.

First, we take up ITA No.653/PUN/2024 for assessment year 2016-17 as the lead case. Facts of the case in brief, are that the assessee is a domestic company in which public are not substantially interested and is engaged in life insur

The order continues below.

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